ADV PART 2 APPENDIX 1
Tvamp, LLC (CRD 160321), brochure dated September 27, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Appendix 1 of Form ADV
Wrap Fee Program Brochure
For Clients and Prospective Clients
September 22, 2026
6025 Brookvale Lane, Suite 160
Knoxville, TN 37919
(865)226-9982
____________________________________________________________________________________
This wrap fee program brochure provides information about the qualifications and business practices of
TVAMP, LLC (also referred to as we, us and TVAMP throughout this disclosure brochure). If you have
any questions about the contents of this disclosure brochure, please contact Jeffrey B. Foster at 865-226-
9982 or jeff.foster@tvamp.com. The information in this disclosure brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about TVAMP is also available on the SEC’s website at www.adviserinfo.sec.gov.
You can view our firm’s information on this website by searching for TVAMP, LLC or our firm’s CRD
number 160321.
Registration as an investment advisor does not imply a certain level of skill or training.
Item 2 – Material Changes
TVAMP encourages all current and prospective clients to read this Disclosure Brochure and discuss any
questions you have with the Advisor. Since our last annual updating amendment filed on March 18, 2026,
TVAMP has made the following changes:
References to Services Offered Outside the TVAMP Program
TVAMP has updated this Wrap Fee Program Brochure to reference services TVAMP offers outside the
TVAMP Program, including the management of held-away accounts (such as employer-sponsored
retirement plan accounts) through Pontera, a third-party order management platform, and asset
management services provided through unaffiliated sub-advisers. These services, and the fees and
conflicts of interest associated with them, are described in TVAMP's separate Form ADV Part 2A
Disclosure Brochure.
Correction to Affiliations Disclosure
Item 9 has been corrected to remove a statement that TVAMP does not have a related person that is an
accountant or accounting firm. As disclosed in Item 9, TVAMP is affiliated with TVAMP Tax Planning LLC,
an accounting firm, through common ownership.
Termination of Asset Management Services
TVAMP has added disclosure in Item 4 describing how asset management services terminate and how
advisory fees are handled for terminating accounts, including when advisory fees stop accruing, the
option to direct an immediate stop, the proration and refund of prepaid fees, and the treatment of
accounts transferred without written notice.
We will ensure that you receive a summary of material changes, if any, to this and subsequent disclosure
brochures within 120 days after our fiscal year ends. Our fiscal year ends on December 31 so you will
receive the summary of material changes, if any, no later than April 30 each year. At that time, we will
also offer a copy of the most current disclosure brochure. We may also provide other ongoing disclosure
information about material changes, as necessary.
Item 3 – Table of Contents
Appendix 1 of Form ADV .............................................................................................................................. 1
Item 2 – Material Changes ............................................................................................................................ 2
Item 3 – Table of Contents ............................................................................................................................ 2
Item 4 – Services, Fees and Compensation ................................................................................................. 4
Item 5 – Account Requirements and Types of Clients .................................................................................. 7
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Item 6 – Portfolio Manager Selection and Evaluation ................................................................................... 8
Types of Advisory Services .............................................................................................................. 8
Performance-Based Fees .............................................................................................................. 11
Methods of Analysis ....................................................................................................................... 11
Voting Client Securities .................................................................................................................. 13
Item 7 – Client Information Provided to Portfolio Managers ....................................................................... 13
Item 8 - Client Contact with Portfolio Managers.......................................................................................... 13
Item 9 - Additional Information .................................................................................................................... 14
Disciplinary Information .................................................................................................................. 14
Other Financial Industry Activities and Affiliations ......................................................................... 14
Code of Ethics Summary ............................................................................................................... 15
Account Reviews and Reviewers ................................................................................................... 16
Client Referrals and Other Compensation ..................................................................................... 17
Financial Information ...................................................................................................................... 19
Additional Locations ................................................................................................................................. 20
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Item 4 – Services, Fees and Compensation
TVAMP, LLC (“TVAMP” or “we”) is the sponsor of the TVAMP Asset Management Program (“TVAMP
Program”), a wrap fee program developed through an arrangement using LPL Financial Corporation’s
(“LPL”) Strategic Wealth Management platform. Through the TVAMP Program, we provide investment
management services, including providing continuous investment advice to and making investments for
you based on your individual needs. Through this service, we offer a customized and individualized
investment program. A specific asset allocation strategy and suitability profile is crafted to focus on your
specific goals and objectives. Your information should be updated regularly, but at a minimum every 2
years.
TVAMP Program accounts are custodied at LPL in its capacity as a registered broker/dealer, member
FINRA/SIPC. LPL is also an investment advisor registered with the SEC, but does not serve as an
investment advisor for you through the TVAMP Program. LPL provides clearing, custody and other
brokerage services for accounts established through the TVAMP Program. Therefore, you are required
to establish a brokerage account(s) through LPL’s Strategic Wealth Management platform. Separate
accounts are maintained for you, and you retain all rights of ownership of your accounts (e. g., the right to
withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations).
TVAMP Program accounts allow you to authorize us to purchase and sell, on a discretionary or non-
discretionary basis, portfolios consisting of securities and investments. We may limit our discretion with
respect to your account and the securities eligible to be purchased for your account. See, Limits Advice
to Certain Types of Investments under Item 6 – Types of Advisory Services
During any month that there is activity in the TVAMP Program account, you receive a monthly account
statement from LPL showing account activity as well as positions held in the account at month end.
Additionally, you receive a confirmation of each transaction that occurs within the TVAMP Program
account unless the transaction is the result of a systematic purchase, redemption or exchange. You also
receive a detailed quarterly report showing performance, positions, and activity. All account data and
statements are also available on-line through the account view portal through LPL.
For our asset management services, we provide three options for billing our clients. Clients can be
charged a flat annual fee of up to 2.0% dependent upon the investment adviser representative providing
the services, the type of client, the complexity of the client's situation, the composition of the client's
account, the potential for additional account deposits, and the relationship of the client and the investment
adviser representative; the client can be charged a flat dollar amount (assessed quarterly or annually);
the client can enter into the tiered fee schedule:
Allowable Fee, %
Up to 2.00%
Up to 1.75%
Up to 1.50%
Up to 1.25%
Up to 1.00%
Account Value
On first $100,000
On next $200,000
On next $450,000
On next $750,000
On all other assets
A minimum fee or fixed quarterly fee may apply in certain circumstances, as set forth in the client
agreement. There is a minimum account size of $50,000. However, exceptions to the minimum account
requirements may be granted at the sole discretion of the advisor.
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Fees charged for our asset management services are negotiable based on the investment adviser
representative providing the services, the type of client, the complexity of the client's situation, the
composition of the client's account, the potential for additional account deposits, and the relationship of
the client and the investment adviser representative.
Fees charged for our asset management services are charged based on a percentage of assets under
management, billed in advance (at the start of the billing period) on a quarterly calendar basis and
calculated based on the fair market value of your account as of the last business day of the previous
billing period. Fees are prorated (based on the number of days service is provided during the initial billing
period) for your account opened at any time other than the beginning of the billing period. If asset
management services commence in the middle of a billing period, the prorated fee for the initial billing
period is billed in arrears at the same time as the next full billing period’s fee is billed. All withdrawals
during the billing period, with the exception of adjustments for the deduction of advisory fees, will be
adjusted based on the number of days left in the billing period when calculating the next advisory fee.
LPL is responsible for tracking changes in AUM, and the advisory fee is adjusted accordingly based on
the Custodian’s calculation practices. TVAMP reviews the Custodian’s calculations for accuracy as part of
its fiduciary oversight.
Termination of Asset Management Services
You may terminate asset management services at any time by providing written notice to TVAMP. Your
written notice begins a wind-down period during which TVAMP remains the investment adviser of record
on your account and continues to provide services, including monitoring the account and assisting with
liquidations, raising cash, and transfer paperwork. Advisory fees continue to accrue during the wind-down
period and stop on the earliest of the date your assets transfer out of the account, the date the account is
deactivated with the qualified custodian, or seven (7) days after TVAMP receives your written notice. You
may instead direct TVAMP in writing to cease services immediately, in which case your account will be
deactivated and advisory fees will stop as of that date. If TVAMP terminates services by providing written
notice to you, advisory fees stop as of the effective date stated in TVAMP’s notice. Account deactivation
is processed by the qualified custodian, and processing generally takes one to three business days from
TVAMP’s deactivation request; the deactivation date is determined by the custodian’s processing
procedures, not by TVAMP. In all cases, advisory fees stop no later than seven (7) days after TVAMP
receives your written notice, and any prepaid fees for the period after fees stop are refunded as described
below.
Because advisory fees are billed in advance, any fees paid for the period after fees stop are prorated and
refunded, generally through a credit applied to your account as part of the custodian’s fee adjustment
process or, if your account has been closed or transferred before a credit can be applied, by direct
payment to you. If you transfer your account without providing written notice (for example, by initiating a
transfer to another financial institution), advisory fees stop when the assets transfer out of the account,
and any prepaid fees for the period after that date are prorated and refunded in the same manner.
Custodial, program, platform, and fund-level fees charged by parties other than TVAMP are not advisory
fees and may continue to accrue until your account is closed or deactivated.
TVAMP believes that its annual fee is reasonable in relation to (1) services provided and (2) the fees
charged by other investment advisers offering similar services/programs. However, our annual
investment advisory fee may be higher than that charged by other investment advisers offering similar
services/programs. In addition to our compensation, you may also incur charges imposed at the mutual
fund level (e.g., advisory fees and other fund expenses).
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Prior to engaging us to provide investment management services, you are required to enter into a formal
investment advisory agreement with us setting forth the terms and conditions, including the amount of
investment advisory fees, under which we manage your assets and also a separate custodial/clearing
agreement with LPL.
If you choose to have the investment advisory fees deducted from your account, you must authorize the
qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to
TVAMP. Our firm will send you a billing statement prior to the time that fee deduction instruction is sent to
the qualified custodian(s) of your account. The billing statement will detail the formula used to calculate
the fee, the assets under management and the time period covered.
You should review your account statements received from the qualified custodian(s) and verify that
appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the
accuracy of the investment advisory fees deducted.
If you choose to pay the fees after receiving a statement, fees are due upon your receipt of a billing notice
sent directly to you. The billing notice will detail the formula used to calculate the fee, the assets under
management and the time period covered. Fees for the services of our firm will be due immediately after
your receipt of the billing notice.
The TVAMP Program account is a wrap fee account, meaning you do not pay transaction charges
associated with trade execution. The TVAMP Program may cost you more or less than if the assets were
held in a traditional brokerage account. In a brokerage account, you are charged commissions for each
transaction, and the representative has no duty to provide ongoing advice with respect to the account. If
you plan to follow a buy and hold investment strategy for the account or do not wish to purchase ongoing
investment advice or management services, you should consider opening a brokerage account rather
than a TVAMP Program account.
TVAMP does not receive any portion of such commissions or fees from you or the qualified custodian. In
addition, you may incur certain charges imposed by third parties other than TVAMP in connection with
investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1
fees and surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement
plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged
by TVAMP are separate and distinct from the fees and expenses charged by investment company
securities that may be recommended to you. A description of these fees and expenses are available in
each investment company security’s prospectus.
TVAMP receives compensation in connection with client participation in advisory programs sponsored by
LPL Financial. The amount of compensation received by TVAMP varies depending on the specific
program selected. These differences are based on the fee structure of each program and the
arrangements associated with LPL’s platform.
As a result, TVAMP may receive higher compensation from certain programs than from others or than
from other advisory arrangements. This creates a financial incentive for TVAMP to recommend advisory
programs that result in higher compensation. TVAMP addresses this conflict through its fiduciary duty to
act in the client’s best interest and through supervisory oversight of investment recommendations.
Retirement Plan Rollover Recommendations – TVAMP does not recommend rollovers to our clients or
prospects. The firm’s activities will be strictly limited to educating clients and prospects as to their
options.
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Participation in Wrap Fee Programs
TVAMP offers asset management services through our Asset Management Services Program, which is a
wrap fee management program. In our wrap fee management program, the fee for advisory services
(including portfolio management or advice regarding selecting other investment advisers) and transaction
services are provided for one fee. Whenever a fee is charged to a client for services described in this
Wrap Fee Program Brochure, we will receive all of a portion of the fee charged. In our wrap fee
management program, you may elect to pay expenses under a “traditional” payment option meaning that
advisory services are provided for a fee but transaction services are billed separately on a per-transaction
basis, or you may elect the bundled “wrap fee” payment option meaning that advisory services (including
portfolio management or advice regarding selecting other investment advisers) and transaction services
are provided for one fee. Our Asset Management Services are considered a wrap fee program.
Whenever a fee is charged to a client for services described in this Wrap Fee Program Brochure, we will
receive all of a portion of the fee charged.
From a management perspective, there is not a fundamental difference in the way we manage accounts
that have elected the traditional payment option versus those that have elected the bundled wrap fee
payment option. The only significant difference is the way in which transaction costs are paid.
LPL Financial is the custodian for all WRAP Accounts Managed by TVAMP. As the custodian LPL Is
responsible for the custody, pricing of assets and tracking the performance of the accounts.
From time to time, we may receive expense reimbursement for travel and/or marketing expenses from
distributors of investment products. Travel expense reimbursements are typically a result of attendance
at due diligence and/or investment training events hosted by product sponsors. Marketing expense
reimbursements are typically the result of informal expense sharing arrangements in which product
sponsors may underwrite costs incurred for marketing such as advertising, publishing and seminar
expenses. Although receipt of these travel and marketing expense reimbursements are not predicated
upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for
whom sales have been made or it is anticipated sales will be made. We endeavor at all times to put your
interests first as a part of our fiduciary duty. However, you should be aware that receiving additional
compensation through nominal sales awards, expense reimbursements, etc. creates a conflict of interest
that may impact our judgment when making advisory recommendations.
Client Assets Managed by TVAMP
The amount of client’s assets managed by us totaled $1,185,099,837 as of December 31, 2025.
$1,174,287,250 is managed on a discretionary basis and $10,812,581 is managed on a non-discretionary
basis.
Item 5 – Account Requirements and Types of Clients
Minimum Investment Amounts Required
TVAMP requires a minimum of $50,000 in order to open an account. To reach this account minimum,
clients can aggregate all household accounts. Exceptions may be granted to this minimum based on the
investment adviser representative providing the services, the type of client, the complexity of the client's
situation, the composition of the client's account, the potential for additional account deposits, and the
relationship of the client and the investment adviser representative. You are required to execute a written
agreement with TVAMP specifying the particular services in order to establish a client arrangement with
TVAMP.
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Types of Clients
TVAMP provides advisory services to Individuals and Pension and Profit Sharing plans.
Item 6 – Portfolio Manager Selection and Evaluation
TVAMP and its Investment Adviser Representatives act as the portfolio manager(s) for accounts receiving
our Asset Management Services. Our Asset Management Service is considered a wrap fee program.
For this service, we do not allow the use of portfolio managers that are not associated with TVAMP. In
other words, the only portfolio managers selected for managing client assets for our Asset Management
Services are Investment Adviser Representatives of TVAMP. Therefore, conflicts of interest present in
other wrap fee programs that make available both affiliated and unaffiliated portfolio managers are not
present in our wrap fee program. Because our Asset Management Services program does not provide
for outside portfolio managers, we do not have procedures designed to select or review the performance
of outside portfolio managers.
Types of Advisory Services
In addition to the management services described above, we provide financial planning services,
consultation services, advisement services and pension consulting services. Our financial planning
services include:
• Written financial plans that can be full or modular (segmented) in nature. Fees are billed as either
a fixed or hourly fee charge. Full financial plans include one-year of ongoing financial planning
services at no additional fee. These on-going services can include consultations, reviews and
updates regarding any topic found in the original financial plan.
• Consultation services can be on any topic(s) of interest to you and are billed at an hourly or fixed
fee rate.
• Advisement consultations to participants in benefit plans (401(k) plans, profit sharing plans, etc.)
provided on a one-time or on-going (one-year) basis. We make recommendations regarding
asset allocation and investment selections for the investment portfolio in the plan. There is no fee
charged.
• Periodic newsletters that are educational and informational in nature provided to clients and
prospective clients free of charge.
• Workshops that are educational, informational and motivational in nature. Workshops are always
offered free of charge and are provided on an impersonal basis and do not focus on the individual
needs of the participants.
• Seminars in areas such as financial planning, retirement planning, estate planning and charitable
planning. No fees are charged, although we reserve the right to charge a fee to cover expenses
if seminars are provided to larger groups such as corporations.
• These educational activities are provided for informational purposes only and are not intended as
a solicitation of investment advisory services. Any decision to engage TVAMP for advisory
services is made separately and is subject to the execution of a written advisory agreement.
• Management of held-away accounts (such as employer-sponsored retirement plan accounts)
through the Pontera order management platform, and asset management services provided
outside the TVAMP Program, including through unaffiliated sub-advisers. These services are not
part of the TVAMP Program; they are described, together with the applicable fees, in our
separate Disclosure Brochure.
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Please refer to our separate Disclosure Brochure for full details concerning our advisory services, fees,
billing procedures and termination provisions.
Limits Advice to Certain Types of Investments
TVAMP provides investment advice on the following types of investments:
Interests in Partnerships Investing in Real Estate
Interests in Partnerships Investing in Oil and Gas Interests
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Foreign Issues
• Warrants
• Corporate Debt Securities
• Commercial Paper
• Certificates of Deposit
• Municipal Securities
• Variable Annuities that have been approved for inclusion in the LPL Platform
• US Government Securities
• Options Contracts on Securities
•
•
TVAMP primarily recommends Mutual funds and although we generally provide advice only on the
products previously listed, we reserve the right to offer advice on any investment product that may be
suitable for each client’s specific circumstances, needs, goals and objectives.
When providing asset management services, TVAMP typically constructs each client’s account holdings
using Mutual funds to build diversified portfolios. It is not our typical investment strategy to attempt to
time the market, but we may increase cash holdings modestly as deemed appropriate, based on your risk
tolerance and our expectations of market behavior. We may modify our investment strategy to
accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances,
closely held businesses, collectibles, or special tax situations.
You have the ability to place reasonable restrictions on the types of investments that may be purchased
in your account.
Advisory Services Tailored to Individual Needs of Clients
TVAMP’s services are always provided based on the individual needs of each client. This means, for
example, that clients are given the ability to impose restrictions on the accounts we manage for them,
including specific investment selections and sectors. We work with each client on a one-on-one basis
through interviews and questionnaires to determine their investment objectives and suitability information.
However, we reserve the right to not enter into an investment advisor relationship with a prospective
client whose investment objectives may be considered incompatible with our investment philosophy or
strategies or where the prospective client seeks to impose unduly restrictive investment guidelines.
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Wrap-Fee Program versus Portfolio Management Program
We offer services through both wrap-fee programs and non-wrap fee programs. A wrap fee program is
defined as any advisory program under which a specified fee or fees not based directly upon transactions
in a client’s account is charged for investment advisory services (which may include portfolio
management or advice concerning the selection of other investment advisers) and the execution of client
transactions. Whenever a fee is charged to a client for services described in this brochure (whether wrap
fee or non-wrap fee), we will receive all or a portion of the fee charged.
WRAP Fee Program Disclosure
As representative of LPL Financial, LLC, the investment advisor representatives of TVAMP have the
ability to offer the WRAP account services conducted under the TVAMP SWM-ADV program. Although
clients do not pay a transaction charge for transactions in a SWM-ADV account, clients should be aware
that TVAMP pays LPL transaction charges for those transactions. The transaction charges paid by
TVAMP vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds
based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction
charges paid by the Advisor for equities and ETFs are $9. For mutual funds, the transaction charges
range from $0 to $26.50. Because TVAMP pays the transaction charges in SWM-ADV accounts, there is
a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should
understand that because TVAMP pays these transaction charges, the cost of those charges is a factor
that TVAMP considers when deciding which securities to select and how frequently to place transactions
in a SWM-ADV account. This creates a conflict of interest because TVAMP has an incentive to consider
its own costs when making investment decisions.
In many instances, LPL makes available mutual funds in a SWM-ADV account that offer various classes
of shares, including shares designated as Class A Shares and shares designed for advisory programs,
which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative”
or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual
fund in SWM-ADV in many cases will not be the least expensive share class that the mutual fund makes
available and was selected by LPL in certain cases because the share class pays LPL compensation for
the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand
that another financial services firm may offer the same mutual fund at a lower overall cost to the investor
than is available through SWM-ADV. In other instances, a mutual fund may offer only Class A Shares, but
another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay
LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage-
related services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result
of the different expenses of the mutual fund share classes, it is generally more expensive for a client to
own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time
and keep more of his or her investment returns than an investor who holds Class A Shares of the same
fund. LPL receives 12b-1 fees associated with certain mutual fund share classes. A portion of the
compensation LPL receives is shared with its registered representatives pursuant to its compensation
structure. As a result, TVAMP’s investment adviser representatives receive an indirect financial benefit
from such fees. Other financial services firms may offer the same mutual fund at a lower overall cost to
the investor than is available through the LPL Programs.
TVAMP has a financial incentive to recommend Class A Shares in cases where both Class A and
Platform Shares are available. This is a conflict of interest which might incline TVAMP, consciously or
unconsciously, to render advice that is not disinterested. Although the client will not be charged a
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transaction charge for transactions, Advisor pays LPL a per transaction charge for mutual fund purchases
and sales in the account. TVAMP generally does not pay transaction charges for Class A Share mutual
fund transactions accounts but generally does pay transaction charges for Platform Share mutual fund
transactions. Because TVAMP pays transaction charges for certain transactions, these costs are a factor
that TVAMP considers when deciding which securities to select and whether or not to place transactions
in the account. This creates a conflict of interest because TVAMP has an incentive to reduce its own
costs when making investment decisions.
Performance-Based Fees
Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation
of the assets held in a client’s account. We do not receive performance-based fees.
Methods of Analysis
TVAMP primarily relies on fundamental analysis and asset allocation principles when providing
investment advice.
Fundamental analysis involves evaluating factors such as economic conditions, interest rate
environments, market trends, and characteristics of specific investments including cost structure,
diversification, and historical performance.
TVAMP also evaluates third-party investment managers, model portfolios, and investment strategies
offered through institutional advisory platforms. When selecting or recommending third-party
managers or model portfolios, TVAMP considers factors such as:
Investment Philosophy and Process
•
• Historical Performance
• Risk Management Approach
• Portfolio Diversification
• Cost and Fee Structure
The firm may also consider research and analysis provided by institutional research providers,
program sponsors, or investment strategists.
Investment Strategies
TVAMP generally employs long-term investment strategies designed to align client portfolios with
their investment objectives, time horizon, and tolerance for risk. Investment recommendations are
typically based on strategic asset allocation principles intended to provide diversification across
asset classes and investment styles.
Client portfolios may include a combination of investments such as individual equity securities
(stocks), fixed income securities (bonds), mutual funds, exchange-traded funds (ETFs), model
portfolios, and third-party investment managers. In certain cases, portfolios may be managed
through advisory programs offered by institutional platform providers or through third-party managers
selected based on the client’s objectives and risk profile.
TVAMP may recommend diversified portfolios designed to pursue growth, income, capital
preservation, or a combination of these objectives. Portfolio allocations may be periodically
rebalanced or adjusted based on changes in market conditions, investment opportunities, or
changes in a client’s financial circumstances.
In some circumstances, client accounts may utilize margin, which allows clients to borrow funds from
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a broker-dealer to purchase securities using the securities in the account as collateral. The use of
margin increases both the potential gains and losses of an investment and can increase the volatility
of an account. Clients who use margin will incur interest charges and must maintain minimum equity
levels in their accounts as required by the broker-dealer.
TVAMP does not typically recommend the use of margin as a primary investment strategy; however,
margin may be available within certain brokerage accounts depending on the client’s account
structure and investment objectives. Clients should carefully consider the risks associated with
borrowing before utilizing margin.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. The value of
investments may fluctuate due to changes in market conditions, economic developments, interest rates,
and other factors that are beyond the control of TVAMP. Clients should understand that investment
strategies and investments recommended by TVAMP involve varying degrees of risk and there can be no
assurance that any investment strategy will achieve its intended objective.
The principal risks associated with the investment strategies used by TVAMP include, but are not limited
to, the following:
Market Risk
The value of securities may fluctuate due to general market conditions, economic developments,
geopolitical events, interest rate changes, or changes in investor sentiment.
Equity Risk
Investments in individual stocks are subject to fluctuations in value due to company-specific
developments, earnings changes, industry conditions, or broader market factors.
Fixed Income Risk
Investments in bonds and other fixed income securities are subject to risks including credit risk, interest
rate risk, and the risk that the issuer may fail to meet its payment obligations.
Interest Rate Risk
When interest rates rise, the value of existing fixed income securities typically declines. Changes in
interest rates may also impact the income generated by fixed income investments.
Inflation Risk
Inflation may reduce the purchasing power of investment returns over time.
Manager Risk
When third-party investment managers, strategists, or model portfolios are utilized, their investment
decisions may not perform as expected, which could result in losses.
Retirement Plan / ERISA Fiduciary Risk
When providing services to retirement plans governed by the Employee Retirement Income Security Act
of 1974 (“ERISA”), TVAMP may act as either a non-discretionary fiduciary under ERISA §3(21) or a
discretionary investment manager under ERISA §3(38), depending on the agreement with the plan
sponsor. In these roles, TVAMP provides investment recommendations or investment management
services to the plan.
Liquidity Risk
Certain investments may be difficult to sell quickly without significantly affecting the market price,
particularly during periods of market stress.
Concentration Risk
Portfolios that are concentrated in a particular security, industry, or asset class may experience greater
volatility and risk of loss than more diversified portfolios.
ETF and Mutual Fund Risk
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Investments in exchange-traded funds and mutual funds are subject to the risks of the underlying
securities held by the fund as well as the investment decisions of the fund manager. These investments
also include management fees and other expenses that reduce returns.
Margin Risk
When securities are purchased on margin, clients borrow funds from a broker-dealer to purchase
securities using the securities in the account as collateral. The use of margin magnifies both gains and
losses and increases the volatility of the account. If the value of the securities in a margin account
declines, the client may be required to deposit additional funds or securities to maintain the required
equity level. If a margin call is not met, the broker-dealer may liquidate securities in the account without
prior notice.
Digital Asset-Linked Investment Risk
Certain investment vehicles, such as exchange-traded funds that track bitcoin or other digital asset
benchmarks, may provide indirect exposure to digital assets. These investments may experience
heightened volatility, regulatory uncertainty, liquidity constraints, and tracking error risk relative to the
underlying asset.
Voting Client Securities
TVAMP does not vote proxies on your behalf. You should read through the information provided with the
proxy-voting documents and make a determination based on the information provided. If requested, we
may provide limited clarifications of the issues presented in the proxy voting materials based on our
understanding of issues presented in the proxy-voting materials. However, you have the ultimate
responsibility for making all proxy-voting decisions.
With respect to assets managed by any outside money manager, we do not vote the proxies associated
with these assets. You need to refer to each outside money manager’s disclosure brochure to determine
whether the outside money manager will vote proxies on your behalf. You may request a complete copy
of sub-advisor’s proxy voting policies and procedures as well as information on how your proxies were
voted by contacting us at the address or phone number indicated on Page 1 of this disclosure document.
Item 7 – Client Information Provided to Portfolio Managers
Periodically we may need to provide certain financial information about clients to a portfolio manager.
This requirement may be necessary when working with an investment that has certain net worth or
income requirements. This information may be supplied to the portfolio manager each year as necessary.
The information is only provided to establish financial suitability/wherewithal for the specific investment.
Item 8 - Client Contact with Portfolio Managers
Our TVAMP Program primarily utilizes pooled investment vehicles which have investment/portfolio
managers. These managers are not typically available to our clients for direct contact. We have
relationships with those managers’ companies and each provides us with points of contact so that we can
obtain important information, updates and analysis necessary and relevant for our portfolio decision
making process. Periodically we may be in direct contact with an investment’s manager to obtain their
view on certain market events. This meeting usually does not include clients.
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Sometimes, however, we may offer a workshop or seminar in which we bring in a portfolio manager. That
manager may give his/her overall market outlook and discuss some attributes of the portfolio. These
workshops or seminars are for general educational purposes only.
Item 9 - Additional Information
Disciplinary Information
We have no legal or disciplinary events that are material to your evaluation of our business or the integrity
of our management. Therefore, this item is not applicable to our brochure.
Other Financial Industry Activities and Affiliations
TVAMP is not and does not have a related person that is a broker/dealer, municipal securities dealer,
government securities dealer or broker, an investment company or other pooled investment vehicle
(including a mutual fund, closed-end investment company, unit investment trust, private investment
company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures
commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift
institution, a lawyer or law firm, a pension consultant, a real estate broker or dealer, and a sponsor or
syndicator of limited partnerships.
We are an independent registered investment registered advisor and only provide investment advisory
services. We are not engaged in any other business activities and offer no other services except those
described in this Disclosure Brochure. However, while we do not sell products or services other than
investment advice, our representatives may sell other products or provide services outside of their role as
investment advisor representatives with us.
Registered Representative of a Broker-Dealer
Our representatives are also registered representatives of LPL Financial, a securities broker-dealer. You
may work with your investment adviser representative in his or her separate capacity as a registered
representative of LPL Financial. When acting in his or her separate capacity as a registered
representative, your investment adviser representative may sell, for commissions, general securities
products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity products to
you. As such, your investment adviser representative may suggest that you implement investment advice
by purchasing securities products through a commission-based brokerage account in addition to or in lieu
of a fee-based investment-advisory account. This receipt of commissions creates an incentive to
recommend those products for which your investment adviser representative will receive a commission in
his or her separate capacity as a registered representative of a securities broker-dealer. Consequently,
the objectivity of the advice rendered to you could be biased.
You are under no obligation to use the services of our representatives in this separate capacity or to use
LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you
select our representatives to implement securities transactions in their separate capacity as registered
representatives, they must use LPL Financial. Prior to effecting any transactions, you are required to
enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial may
be higher or lower than those charged by other broker/dealers.
TVAMP Advisor Representatives Other Business Activities – Banking or Thrift Institutions
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TVAMP has established and will continue to establish marketing arrangements with banks and other
depository institutions whereby investment advisory services of TVAMP may be marketed through these
banks and other depository institutions, provided that such marketing is done in compliance with
applicable SEC and state regulations. Further, TVAMP may have investment adviser representatives
conducting business from and/or affiliated with a bank or other depository institution. These relationships
may create compliance issues related to consumer protection.
Insurance Agent
TVAMP is licensed as an Insurance Agency with the state of Tennessee and Ohio. In January of 2023
TVAMP became a licensed Insurance Agency with the State of Georgia. In 2024 TVAMP became
licensed as a nonresident Insurance Agency with the State of Texas and Florida.
You may work with your investment adviser representative in his or her separate capacity as an
insurance agent though the TVAMP agency. You may work with your investment adviser representative
in his or her separate capacity as an insurance agent. When acting in his or her separate capacity as an
insurance agent, the investment adviser representative may sell, for commissions, general disability
insurance, life insurance and annuities to you. As such, your investment adviser representative in his or
her separate capacity as an insurance agent, may suggest that you implement recommendations of
TVAMP by purchasing disability insurance, life insurance or annuities. This receipt of commissions
creates an incentive for the representative to recommend those products for which your investment
adviser representative will receive a commission in his or her separate capacity as an insurance agent.
Consequently, the advice rendered to you could be biased. You are under no obligation to implement
any insurance or annuity transaction through your investment adviser representative.
TVAMP Tax
TVAMP is affiliated with TVAMP Tax, an accounting firm that prepares tax returns, through common
ownership. This is a conflict of interest. TVAMP has an incentive to recommend TVAMP Tax to provide
tax services to its clients because it is an affiliate of TVAMP. Additionally, the compensation paid to
TVAMP Tax is based on the client’s assets managed by TVAMP. We mitigate this conflict by ensuring the
recommendation to use TVAMP Tax is in the clients’ best interest
Code of Ethics Summary
An investment advisor is considered a fiduciary and has a fiduciary duty to all clients. TVAMP has
established a Code of Ethics to comply with the requirements of the securities laws and regulations that
reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires
compliance with federal securities laws. TVAMP’s Code of Ethics covers all individuals that are classified
as “supervised persons”. All employees, officers, directors and investment advisor representatives are
classified as supervised persons. TVAMP requires its supervised persons to consistently act in your best
interest in all advisory activities. TVAMP imposes certain requirements on its affiliates and supervised
persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct
required is higher than ordinarily required and encountered in commercial business.
This section is intended to provide a summary description of TVAMP’s Code of Ethics. If you wish to
review the Code of Ethics in its entirety, you should send a written request and upon receipt of your
request, a copy of the Code of Ethics will promptly be provided to you.
Affiliate and Employee Personal Securities Transactions Disclosure
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TVAMP or associated persons of the firm may buy or sell for their personal accounts, investment products
identical to those recommended to clients. This creates a potential conflict of interest. It is the express
policy of TVAMP that all persons associated in any manner with our firm must place clients’ interests
ahead of their own when implementing personal investments. TVAMP and its associated persons will not
buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by
information obtained as a result of employment or association with our firm unless the information is also
available to the investing public upon reasonable inquiry.
We are now and will continue to be in compliance with applicable state and federal rules and regulations.
To prevent conflicts of interest, we have developed written supervisory procedures that include personal
investment and trading policies for our representatives, employees and their immediate family members
(collectively, associated persons):
• Associated persons cannot prefer their own interests to that of the client
• Associated persons cannot purchase or sell any security for their personal accounts prior to
implementing transactions for client accounts
• Associated persons cannot buy or sell securities for their personal accounts when those
decisions are based on information obtained as a result of their employment, unless that
information is also available to the investing public upon reasonable inquiry
• Associated persons are prohibited from purchasing or selling securities of companies in which
any client is deemed an “insider”
• Associated persons are discouraged from frequent personal trading
• Associated persons are generally prohibited from serving as board members of publicly traded
companies unless an exception has been granted TVAMP’s Chief Compliance Officer.
Any associated person not observing our policies is subject to sanctions up to and including termination.
Account Reviews and Reviewers
Account reviews are made on a regular basis during a calendar year. Account reviews will include
investment strategy and objectives review and making a change if strategy and objectives have changed.
Reviews are conducted by the investment advisor representative assigned to the account with reviews
performed in accordance with your investment goals and objectives.
Managed accounts are reviewed at least quarterly. While the calendar is the main triggering factor,
reviews can also be conducted at your request.
Accounts established and maintained with other third-party money managers are reviewed at least
quarterly, usually when statements and/or reports are received from the money manager.
Our financial planning services may terminate upon the presentation of the written plan or may continue
depending on the arrangement with the client. Our financial planning and consulting services do not
include monitoring the investments of your account(s), and therefore, there’s no ongoing review of your
account(s) under such services.
Statements and Reports
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For our asset management services, you are provided with transaction confirmation notices and regular
quarterly account statements directly from the qualified custodian. Additionally, TVAMP may provide
position or performance reports to you quarterly and upon request.
Whether reports by outside money manager are provided to you will depend upon the outside money
manager.
Financial planning clients will receive reports as agreed between you and our firm, which may include a
comprehensive written plan and progress reports over time.
You are encouraged to always compare any reports or statements provided by us, a sub-advisor or third-
party money manager against the account statements delivered from the qualified custodian. When you
have questions about your account statement, you should contact our firm and the qualified custodian
preparing the statement.
Client Referrals and Other Compensation
TVAMP has entered into agreements with various parties (Referring Parties) to refer clients to TVAMP. If
a referred client enters into an investment advisory agreement with TVAMP, a cash referral fee is paid to
the referring party, which is based upon a percentage of the client advisory fees that are generated. The
referral agreements between any referring party and TVAMP will not result in any charges to clients in
addition to the normal level of advisory fees charged.
When a client is referred to us by a referring party, the referring party provides the client with a copy of
our Disclosure Brochure as required by the Investment Advisers Act of 1940. At or before the time of the
referral, the client will also receive a separate promoter disclosure describing the referring party’s
relationship with TVAMP and the compensation paid, as required by Rule 206(4)-1 under the Investment
Advisers Act of 1940 (the “Marketing Rule”). If the referring party is an unaffiliated registered investment
adviser firm, then the client will also receive a copy of the referring party’s Form ADV Part 2 Disclosure
Brochure. If a referred client enters into an investment advisory agreement with TVAMP, a referral fee is
paid to the referring party. The referral relationship will not result in clients being charged any fees over
and above the normal advisory fees charged for the advisory services provided.
The referral agreements between TVAMP and referring parties are in compliance with the Marketing Rule
and applicable state securities rules governing compensated referral arrangements
Marketing Arrangements with Financial Institutions
TVAMP has established and will continue to establish marketing arrangements with banks, credit unions
and other financial institutions. In certain circumstances, investment advisory services of TVAMP may
also be marketed through these banks, credit unions and other financial institutions, provided that such
marketing is done in compliance with applicable SEC and state regulations. Further, TVAMP may have
Advisor Representatives conducting business from and/or affiliated with a bank or other financial
institution. As a result of these marketing agreements, the financial institution may receive compensation
representing payment for the use of the facilities and equipment of the financial institution(s), in the form
of program support or rent payment and/or a portion of advisory fees or securities commissions paid to
the representatives for sales to customer/members of the financial institution.
These relationships may create compliance issues related to consumer protection.
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The joint guidelines of regulators of the depository institution call for, at a minimum, both written and
verbal disclosure at or prior to the time securities products are purchased or sold that such securities
products:
• Are not insured by the Federal Deposit Insurance Corporation (FDIC) or National Credit Union
Share Insurance Fund, the Federal Deposit Insurance Corp., the National Credit Union
Administration, or any other federal or state deposit guarantee fund or other government agency;
• Not endorsed or guaranteed by the bank or credit union or their affiliates;
• Are not deposits or obligations of the depository institutions and are not guaranteed by the
depository institutions;
•
Investments and securities are subject to investment risks, including possible loss of principal
invested.
Broker Dealer Additional Compensation
TVAMP and/or its Dually Registered Persons are incented to join and remain affiliated with LPL Financial
(“LPL”) and to recommend that clients establish accounts with LPL Financial through the provision of
Transition Assistance (discussed in Item 12 above). LPL also provides other compensation to TVAMP
and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable
loans, stock awards and other benefits.
The receipt of this compensation creates a financial incentive for TVAMP and its dually registered
persons to recommend LPL Financial as custodian for client assets and to utilize advisory programs,
services, and investment products available through LPL’s platform. This creates a conflict of interest
because these incentives may influence recommendations made to clients. TVAMP addresses this
conflict through its fiduciary duty to act in the client’s best interest and through supervisory oversight of
investment recommendations.
Promoter Arrangement with an Online Referral Platform
TVAMP has entered into a written referral agreement with an unaffiliated SEC-registered investment
adviser that operates an online referral platform (the “Promoter”). The Promoter refers prospective clients
to TVAMP through its online platform.
If you are referred by the Promoter and engage TVAMP for advisory services, TVAMP pays the Promoter
a referral fee based on a percentage of the advisory fees TVAMP receives from you. For asset-based
advisory relationships, this compensation continues for the duration of the advisory relationship. For fixed-
fee or hourly engagements, the referral compensation is paid for a limited period as specified in the
referral agreement. The referral fee is paid solely by TVAMP and does not result in any additional charge
to you or increase the advisory fee you pay.
The Promoter is not authorized to provide investment advice on behalf of TVAMP or to bind TVAMP in
any manner. An advisory relationship is established only upon execution of a written agreement between
you and TVAMP.
This arrangement creates a conflict of interest because TVAMP shares advisory revenue with the
Promoter for referred clients. The Promoter also has an incentive to recommend TVAMP because it
receives compensation from TVAMP. Clients are under no obligation to engage TVAMP for advisory
services. The Promoter also serves as a sub-adviser for certain TVAMP client accounts outside the
TVAMP Program, as described in Items 4, 5 and 10 of TVAMP's Form ADV Part 2A Disclosure Brochure.
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Additional Compensation
TVAMP’s primary compensation for advisory services consists of the fees described in Item 5 of this
Disclosure Brochure. As described in Item 14, TVAMP may compensate third parties for client referrals.
TVAMP does not receive additional third-party compensation in connection with providing investment
advice, except as disclosed in this Brochure.
Please refer to Item 5 (Fees and Compensation), Item 10 (Other Financial Industry Activities and
Affiliations), Item 12 (Brokerage Practices), and Item 14 (Client Referrals and Other Compensation) for
additional information regarding compensation and related conflicts of interest.
From time to time, TVAMP or its representatives may receive expense reimbursements for travel and/or
marketing expenses from distributors or sponsors of investment or insurance products. Travel
reimbursements are typically associated with attendance at due diligence or investment training events
hosted by product sponsors. Marketing reimbursements may include support for costs related to client
events, seminars, advertising, or educational materials.
Although these reimbursements are not conditioned upon the achievement of specific sales quotas, they
are generally provided by sponsors whose products are used or may be used by clients. This creates a
conflict of interest because it presents an incentive to recommend certain products or services. TVAMP
addresses this conflict by basing all investment recommendations on the individual needs, objectives, and
best interests of its clients.
Financial Information
This item is not applicable to this brochure. TVAMP does not require or solicit prepayment of more than
$1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a
balance sheet for the most recent fiscal year. We are not subject to a financial condition that is
reasonably likely to impair our ability to meet contractual commitments to clients. Finally, TVAMP has not
been the subject of a bankruptcy petition at any time.
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Additional Locations
6154 Popes Creek Place
Haymarket, VA
703-754-2839
11566 Chapman Highway
Seymour, TN 37865
(865) 577-1922
4273 Olde Mill Ln NE
Atlanta, GA 30342
306 Main Street
Jacksboro, TN 37757
(423) 566-4000
1113 Hunter’s Crossing
Alcoa, TN 37701
(865) 226-9982
1339 Volunteer Parkway
Bristol, TN 37620
(865)544-5400
(865) 544-5400
662 E. Broadway Blvd
2004 N. Roan Street
Jefferson City, TN 37760
Johnson City, TN 37601
(865) 544-5400
(865) 544-5400
2518 E. Stone Drive
4611 Kingston Pike
Kingsport, TN 37660
Knoxville, TN 37919
(865) 544-5400
(865) 544-5400
31 Market Square
7459 Maynardville Pike
Knoxville, TN 37902
Knoxville, TN 37938
(865) 544-5400
(865) 544-5400
4118 Asheville Hwy
1974 Town Center Blvd
Knoxville, TN 37914
Knoxville, TN 37922
(865) 544-5400
(865) 544-5400
1316 Wilson Rd
4520 Greenway Drive
Knoxville, TN 37912
Knoxville, TN 37918
(865)544-5400
(865)544-5400
455 Market Drive
2325 Market Place Drive
Lenoir City, TN 37771
Maryville, TN 37801
(865) 544-5400
(865)544-5400
3101 Millers Point Drive
5327 Winner’s Circle Rd
Morristown, TN 37813
Morristown, TN 37813
(865)544-5400
(865)544-5400
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ADDITIONAL LOCATIONS – continued
4310 Winkler Ave
1916 Roane State Highway
Morristown, TN 37814
Harriman, TN 37748
(865)544-5400
(865)544-5400
1037 Middlecreek Rd
7210 Chapman Hwy
Sevierville, TN 37862
Knoxville, TN 37920
(865)544-5400
(865)544-5400
5271 Highway 11E
Piney Flatts, TN 37686
(865) 544-5400
7515 Central Avenue Pike
Powell, TN 37849
(865) 544-5400
11490 Parkside Drive
102 N Seven Oaks Drive
Farragut, TN 37934
Knoxville, TN 37922
(865)544-5400
(865)544-5400
711 W 1st North St.
Morristown, TN 37814
(423) 616-0182
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